What Documents Should Be On-Site During an Environment Agency Visit?

Managing end-of-life tyres (ELTs) is one of the more tightly controlled activities in the waste sector. The risks are well-known: fire, stockpile collapse, arson, environmental harm, and commercial operators entering the market without suitable controls. As a result, the Environment Agency (EA) places a heavy emphasis on robust management systems, site design, fire prevention controls and technical competence long before a permit can be issued. With 24 years in the waste industry and extensive experience preparing permit applications, this guide sets out exactly what operators need to know before applying — and what the EA expects to see before they will even consider granting permission. This article is purposely written in a practical, straight-talking way for operators, recyclers, hauliers, and new entrants to the tyre sector. 1. Understanding the Regulatory Scope for End-of-Life Tyres End-of-life tyres are regulated as non-hazardous waste, but the regime surrounding them is far more restrictive than most non-hazardous streams due to two primary risks: Fire Stockpile instability and abandonment The EA regulates tyres through: Environmental Permitting Regulations (EPR) 2016 Fire Prevention Plans (FPP) Guidance Specific waste codes related to tyres 16 01 03 – End-of-life tyres Control of major accident hazards (COMAH) thresholds, where applicable Duty of care and storage limits Most tyre operations will require a bespoke environmental permit rather than a Standard Rules Permit because ELTs typically breach SRP limits or require treatment not covered under standard rules. If you intend to: Store tyres Shred tyres Treat tyres mechanically Bale tyres Export tyres Produce shred, chips, or crumb rubber …then a permit will be required. Operators who underestimate the regulatory load associated with tyres are very unlikely to progress through permitting smoothly. 2. Common Activities Involving End-of-Life Tyres Most tyre businesses fall into one or more of the following categories: 2.1. Storage Only Tyres are stored before onward transport to recovery or recycling. Permits limit: Maximum tonnage stored Stack height Stack footprint Separation distances Fire compartments Even a “storage only” operation requires a full Fire Prevention Plan. 2.2. Mechanical Shredding Includes shredding whole tyres into: 150mm shred 50mm shred PAS 107 specification products Mechanical treatment increases fire risks and therefore requires detailed engineering controls, ATEX consideration and strict maintenance systems. 2.3. Baling or Processing Required for export or commercial resale. Baling has caused some of the most serious tyre site fires in the UK due to inadequate separation and overstocking. 2.4. Mobile Plant Tyre Shredding Requires a mobile plant permit registered by an operator with a fixed base, including waste acceptance and tracking systems. If your site does any combination of storage and treatment, the EA expects a high level of management sophistication. 3. What the EA Looks for Before They Approve Tyre Sites End-of-life tyre permits attract heavy scrutiny. Inspectors will typically assess: 3.1. Technical Competence (TCM Requirements) Operators must demonstrate: A suitable TCM with relevant WAMITAB units Continuous cover (not a TCM “on paper”) A CPD plan The EA views tyre sites as higher risk, so they expect technical leadership to be robust and demonstrable. 3.2. Fit and Proper Person Test The EA will consider: Past compliance history Financial competence Criminal convictions Previous site abandonment Insolvency events Tyre operations have historically been associated with rogue operators, so the EA’s tolerance for risk is extremely low. 3.3. Fire Prevention Plan (FPP) No tyre permit will be granted without an FPP fully accepted by the EA. Your FPP must demonstrate: Maximum storage tonnage Stack dimensions 6m separation distances Site layout Ignition source control Quarantine areas Firewater containment Access for emergency services Stock rotation strategy Maximum dwell time Tyre-related fires are notoriously difficult to extinguish, and many have burned for days or weeks, causing millions in damages. This is why the EA scrutinises the FPP more aggressively than any other part of the application. 3.4. Waste Acceptance Procedures Before tyres arrive on site, operators must have: Inspection procedures Load rejection criteria Controls against contamination Acceptance documentation Tracking and storage location systems Tyres often arrive mixed with: Rims Rubber strip Metal wire Plastics General waste Contamination causes fires, sparks, and equipment hazards. 3.5. Firewater and Pollution Risk Your application must include: Pollution inventory Secondary containment Surface water protection Drainage plan Accident management procedures The EA will reject applications that cannot demonstrate secure control of firewater run-off. 4. Site Design: The Foundation of a Successful Permit Application Tyre sites must be designed with: 4.1. Clear traffic flow Separate pedestrian and vehicle routes, turning areas for HGVs, and clear signage. 4.2. Adequate surface infrastructure Concrete surfaces free from cracks and potholes are essential for fire control and drainage integrity. 4.3. Sufficient space for stack separation Operators regularly underestimate how much space 500 tonnes of tyres requires. 4.4. Security High fencing, anti-arson measures, and CCTV. Tyre sites are frequent targets of arson. 4.5. Power supply Mechanical shredders have high load demands. A common reason applications fail is that the operator tries to make the site fit the permit, instead of designing a permit that fits the site. 5. Management System Requirements Your management system (MS) should demonstrate: Training and competency Daily inspections Tyre rotation and stock tracking Housekeeping checks Maintenance records At least one named senior manager responsible for environmental performance TCM involvement and oversight The EA expects management systems to be site-specific, not generic templates. 6. Demonstrating Financial Competence Operators must prove they can: Manage site operations Fund fire prevention measures Maintain shredding machinery Cover clean-up costs if stockpiles must be removed Abandoned tyre sites are one of the largest financial liabilities in the waste sector. Expect the EA to scrutinise your financial modelling and contingency costs. 7. Maximum Storage Capacity and Throughput You must define: Maximum storage on site Maximum operational stock Annual throughput Retention and dwell time The EA will assess whether your stated throughput is realistic when compared to: Shredder capacity Staffing Operating hours Export markets Site size If you cannot demonstrate that tyres will not accumulate, your application will be refused. 8. Common Reasons Tyre Permit Applications Are Rejected After supporting operators through many tyre permit applications, these are the most frequent reasons for regulator refusal: ❌ FPP not acceptable ❌ Stockpiles too large ❌ Inadequate site drainage ❌ Lack of genuine TCM involvement ❌ Unrealistic throughput claims ❌ History of poor compliance ❌ Inadequate financial evidence ❌ No demonstrable storage rotation strategy ❌ Sub-standard infrastructure (gravel yards, broken concrete) Tyre permits are awarded only to operators who can clearly demonstrate control and stability. 9. Preparing a Successful Application: What Operators Should Do Step 1 – Commission a Feasibility Assessment Identify: Whether the site is suitable What infrastructure is missing Compliance gaps Step 2 – Prepare detailed site drawings Including stack layout, drainage, fire access, quarantine area. Step 3 – Develop a robust Fire Prevention Plan Expect several rounds of EA feedback. Step 4 – Create a site-specific EMS Housekeeping, acceptance, training, maintenance, and contingency controls. Step 5 – Outline your TCM structure Demonstrate continuous and effective management. Step 6 – Engage with the local Fire & Rescue Service Their comments can strengthen your FPP. Step 7 – Submit a high-quality permit application Include everything the EA expects up front. Step 8 – Maintain compliance from day one Permit conditions are legally binding the moment the permit is issued. 10. What a Good Tyre Site Looks Like (From a Compliance Perspective) A compliant facility has: Hardstanding Clearly marked stacks 6m separation Good drainage No vegetation Daily inspection logs A high level of housekeeping Competent staff Controlled access CCTV and security measures Shredder maintenance logs A safe loading/unloading system Good sites look organised. Bad tyre sites look cluttered, chaotic, and unstable — and the EA can spot the difference instantly. 11. Final Thoughts: Should You Enter the Tyre Sector? Tyre recycling is a growing industry with strong demand for: Shred Crumb Reuse Export Civil engineering applications However, it is also a sector with: High regulatory scrutiny Serious fire risks High equipment costs Strict compliance expectations If you cannot demonstrate operational discipline, this is not the area to cut your teeth in. But for operators who invest properly, demonstrate competence, and maintain control, tyre recycling can be a profitable and future-proof waste stream. Need Support With a Tyre Permit? I support operators with: Feasibility assessments Environmental permit applications Fire Prevention Plans Site layout design EMS development TCM oversight Pre-application EA engagement If you want your tyre permit to progress smoothly, professional preparation is essential.

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One major development is the government’s plan to introduce mandatory digital waste tracking starting from April 2026. This new system is a core part of the UK’s Resources and Waste Strategy and aims to revolutionise how waste is tracked, regulated, and managed across all sectors. What Is Mandatory Digital Waste Tracking? Digital waste tracking will create a centralised, real-time electronic system for recording the movement and treatment of waste throughout the UK. It will replace outdated, fragmented, and mostly paper-based systems with a streamlined digital platform accessible to waste producers, carriers, brokers, regulators, and disposal sites. This means businesses and regulators will have access to reliable, up-to-date information on: Where waste is produced Who is handling it How it is being treated or recycled Where it ultimately ends up Why Is This Important? The digital tracking system will deliver multiple benefits for waste compliance, environmental protection, and the circular economy: Stronger Duty of Care Compliance: Businesses will be better equipped to meet their legal responsibilities for waste management by having clearer, digital records of waste transfers and processing. Effective Waste Regulation: Environmental regulators will gain improved tools to monitor compliance, prioritise inspections, and swiftly act against waste crime such as illegal dumping, misclassification, and unauthorised exports. Combatting Waste Crime: Digital tracking will reduce opportunities for criminals to operate unregulated, protecting legitimate waste businesses and the environment. Supporting a Circular Economy: By fully tracking waste streams, we can maximise resource recovery, reduce landfill, and increase recycling rates, moving towards more sustainable waste management. Smarter, More Efficient Systems: The new digital service will be scalable, secure, and user-friendly, making it easier for all businesses involved in the waste chain to comply with regulations without unnecessary burdens. Working Together Across the UK While waste management is a devolved matter, the UK government, Scottish Government, Welsh Government, and Northern Ireland’s Department of Agriculture, Environment and Rural Affairs are working in partnership to deliver a UK-wide, harmonised digital waste tracking system. This collaboration ensures consistent standards and data sharing across all four nations. What Does This Mean for Your Business? From April 2026, if you produce, transport, treat, or dispose of waste, you will likely be required to use the new digital waste tracking platform. This means: Entering key waste data electronically instead of relying on paper-based waste transfer notes. Keeping up-to-date digital records that are easier to audit and share with regulators. Understanding and adapting to changes in waste duty of care requirements as the legislation evolves alongside the system. Stay Ahead of Waste Regulation Changes Mandatory digital waste tracking marks a significant step forward in the UK’s environmental strategy to improve waste management, fight waste crime, and promote sustainability. Keeping your business compliant will protect you from penalties and contribute to a greener, more circular economy. Visit our website or contact Waste Consultancy today to learn more about preparing for digital waste tracking and other essential waste management compliance services.

One of the most fundamental legal obligations you must meet is the Waste Duty of Care. This duty exists to ensure waste is managed safely, responsibly, and legally from the moment it leaves your control until final disposal or recovery. What Is Waste Duty of Care? The Waste Duty of Care is a legal framework under the Environmental Protection Act 1990. It requires every business producing, storing, transporting, or disposing of waste to take reasonable steps to ensure waste is handled without causing harm to the environment or public health. Key Responsibilities under Duty of Care: Secure Storage: Waste must be stored in a way that prevents escape or pollution. For example, construction waste should be kept in locked skips or containers that prevent wind-blown debris. Use Authorised Waste Carriers: You must only transfer waste to carriers who hold a valid waste carrier licence issued by the Environment Agency or equivalent authority. Provide and Keep Waste Transfer Notes (WTNs): Each time you transfer waste, a detailed WTN must be completed, outlining waste type, quantity, carrier details, and destination. Keep Records: Waste transfer documentation and other compliance records must be kept for a minimum of two years. Proper Waste Classification: Using correct waste codes ensures that hazardous and non-hazardous wastes are identified and managed appropriately. Why Is Duty of Care So Important? Non-compliance with Duty of Care obligations can result in severe penalties including fines, prosecution, or even closure of your site. Improper waste management risks environmental pollution, public health hazards, and damages your business reputation. How Waste Consultancy Supports You We help businesses like yours by providing practical guidance on Duty of Care compliance. From training staff on proper waste handling, verifying waste carrier licences, to reviewing your waste transfer documentation, our experts ensure you meet your legal obligations with confidence.

Under the Environment Agency's updated charging rules, each waste exemption falls into a charging band. Charges include: £56 registration fee per site (one-off, not per exemption) Compliance charge per exemption, based on its band Discounts apply when registering more than one exemption in bands Upper, 1 or 2 🟥 UPPER BAND – High-risk, higher-cost exemptions 💷 Full charge: £1,236 💷 Discounted (additional exemptions): £227 T8 – Mechanically treating end-of-life tyres T9 – Recovering scrap metal U16 – Using depolluted end-of-life vehicles for parts 🟧 BAND 1 – Common treatment and storage activities 💷 Full charge: £420 💷 Discounted (additional exemptions): £76 S1 – Storing waste in secure containers S2 – Storing waste at a secure site T4 – Storing and preparing for further treatment T5 – Screening and blending waste T6 – Treating waste wood and plant matter T10 – Sorting waste for recycling T12 – Manually treating waste T21 – Recovering waste at waste water treatment works T24 – Anaerobic digestion on farms T25 – Anaerobic digestion not on farms U1 – Using waste in construction U9 – Using waste to manufacture finished goods 🟨 BAND 2 – Moderate complexity or specialist waste streams 💷 Full charge: £212 💷 Discounted (additional exemptions): £76 S3 – Storing sludge T1 – Treating certain waste to reuse/recycle T2 – Recovering textiles T13 – Treating waste food T14 – Crushing oil filters T15 – Treating aerosol cans T16 – Treating toner/ink cartridges T17 – Crushing fluorescent tubes T19 – Treating edible oil/fat to produce biodiesel T23 – Aerobic composting T30 – Recovering silver from photo/print T31 – Recovering glycol from aircraft de-icers T33 – Recovering central heating oil U2 – Using tyre bales in construction U4 – Burning waste in a small appliance U5 – Using biodiesel from waste U8 – Using waste for a specific purpose U10 – Spreading waste on agricultural land U11 – Spreading waste on non-agricultural land U15 – Mixing pig/poultry ash with manure D1 – Depositing waste from dredging D6 – Incinerating waste produced on site 🟩 BAND 3 – Low-risk activities with flat fee 💷 Full charge: £30 💷 No discounts for additional exemptions T18 – Removing water from clay and paints T20 – Treating waste at a water treatment works T26 – Using a wormery T29 – Carbon filtering pesticide washings T32 – Treating waste in a biobed/biofilter U3 – Using waste in creative installations U6 – Using sludge to reseed treatment works U7 – Using effluent to clean gravel bed U12 – Using mulch U13 – Spreading plant matter where grown U14 – Mixing ash into soil D2 – Depositing waste from train toilets D3 – Depositing waste from a portable toilet D4 – Depositing diseased crops D5 – Depositing waste for testing D7 – Burning wood/plant waste at production site D8 – Burning waste under Plant Health Notice 🟦 NO CHARGE These exemptions are free to register – but must be done by phone, not online. T28 – Sorting and denaturing controlled drugs 🧑‍🌾 Farming Exemptions – Special Rules If you’re registering one or more approved farming exemptions, you’ll pay: 💷 £88 capped compliance charge for all combined farming exemptions 💷 Plus £56 registration fee If your selected exemptions total less than £88, you only pay the lower amount. 📌 Need Help With Waste Exemption Charges? At Waste Consultancy, we take the confusion out of compliance. Whether you're registering new exemptions, unsure which ones apply to your activity, or trying to avoid overpaying — we’re here to help. 📞 Get in touch today to simplify your waste exemption registration and stay compliant.

Big changes have landed for waste sites operating under Standard Rules permits in England. From 18th December 2024, the Environment Agency introduced an overhaul of Environmental Permitting regulations to reflect updated industry standards and to simplify the system. If you currently operate under a Standard Rules permit – or plan to apply for one – you’ll need to understand what’s changed and how it affects your site. 🔄 What’s Changed? The Environment Agency has replaced 28 existing Standard Rules permits with 8 new rule sets. These are already in effect for new applications, and existing permit holders are now transitioning to the updated rules. Here are the new permit sets introduced: SR2022 No.1 – Treatment of waste to produce soil, soil substitutes and aggregate SR2022 No.2 – Mobile treatment of waste to produce soil, soil substitutes and aggregate SR2022 No.3 – Construction, demolition and excavation (CD&E) waste transfer station SR2022 No.4 – Non-hazardous waste recycling (includes storage of asbestos, WEEE, batteries, cables) SR2022 No.5 – Non-hazardous waste transfer (includes storage of asbestos, WEEE, batteries, cables) SR2022 No.6 – Household Waste Recycling Centre SR2022 No.7 – Materials Recycling Facility (MRF) SR2022 No.8 – Waste wood treatment 🗓️ Key Deadlines and Transition Dates New permits are already being issued using the updated rule sets. Existing permit holders will automatically transition. Old permits will remain available online until 27 June 2025, but all sites must be fully compliant with the new rules by then. The EA will be contacting operators directly to explain how the changes apply. 🔍 What’s Different in the New Rules? These changes are not just a tidy-up – they come with important operational impacts. You’ll need to review your current permit carefully, as: Some permits are now more restrictive, while others offer greater flexibility. Waste codes have been updated to reflect changes in classification (e.g. cables, WEEE). Tonnage and storage limits have been adjusted for some activities. Some activities have been merged to remove duplication or unused permits. Environmental controls have been tightened to align with modern standards. For example, you might now be required to track waste differently, implement new infrastructure, or submit updated documentation. 👷 Do You Still Meet Technical Competence Requirements? If you're working under the CIWM/WAMITAB competence scheme, you’ll also need to review whether your current qualifications still align with the updated permit conditions. Changes to activity types or waste types might mean you need to add new units to your certificate or complete refresher training. CIWM have issued supporting FAQs on this. 💡 How Waste Consultancy Can Help At Waste Consultancy, we’re here to guide you through the permitting changes with clear, no-jargon advice. Whether you're unsure which new SR permit applies, or want to ensure your operation stays compliant before the deadline – we’ve got you covered. We can help with: ✅ Permit audits to assess if your operation still fits the Standard Rules ✅ Support with new environmental permit applications ✅ Waste classification reviews (to ensure codes and activities are correctly applied) ✅ Advice on exemptions, storage limits, and operational impact ✅ Competence scheme advice and CIWM unit mapping 🧾 Stay Ahead of the Changes Don’t wait until your permit is invalid or enforcement action is looming. These changes affect thousands of permitted waste sites – from recycling yards to transfer stations. 👉 Need help understanding how the 2025 changes impact your business? We offer tailored support to waste sites of all sizes. Contact us today for a quick chat or a formal site review. 📞 [Insert contact details or link to contact page] 🌐 www.wasteconsultancy.co.uk